CDC Good Practice. Preventing Fatalities and Serious Accidents

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1 CDC Good Practice Preventing Fatalities

2 What s this guide for? CDC Group, London At CDC we have chosen to focus the impact we seek to achieve on the creation of jobs. This is because of the enormous impact a job has on the life of an individual and their family, especially in lifting themselves out of poverty. However, although we want to support the creation of as many jobs as possible, especially in places where the private sector is weak and formal employment low, we also care intensely about the conditions of workers and their safety. Any workplace or work-related accident is a tragedy and can have ramifications well beyond the life of the individual affected. And so, helping management teams (either directly or through our partner fund managers) to prevent and reduce accidents is a priority for us. It receives explicit Board attention and this guidance is part of our desire to achieve safer workplaces across Africa and South Asia. Diana Noble, CEO This guide details the causes and potential impacts of fatal accidents and provides practical guidance for fund managers and investors to help prevent the occurrence of such accidents. Section 2 in particular provides detailed and actionable guidelines. We anticipate that sections of the guide will be valuable for those responsible for workplace safety within companies as well.

3 01 What s in this guide? Section Section Section Context Preventing accidents Investor guidance A. Introduction p04 B. CDC s experience and objective for this guidance p06 C. Cost and impact of accidents p08 D. Key principles of applying health and safety theory to accidents p10 E. What investors can do p14 A. Working at height p22 B. Workplace vehicles p24 C. Moving machinery and flying/falling objects p26 D. Driving on public roads p28 E. Electricity at work p30 F. Safety and security violent incidents at work p32 G. Managing contractors p34 A. Investor response to accidents p38 B. Due diligence guidance p40 C. CDC s serious incident reporting template p42 D. Useful references p44

4 102

5 03 Context 1. Context A. Introduction p04 B. CDC s experience and objective for this guidance p06 C. Cost and impact of accidents Business costs Human costs Business implications p08 D. Key principles of applying health and safety theory to accidents Root cause of accidents Hazards and risks Why do accidents happen? Relevant factors with respect to accidents Prevention principles p10 E. What investors can do Integrating health and safety/accidents within the investment process Investor interventions Certification and ongoing assessment p14

6 04 Context A. Introduction Setting the scene According to the International Labour Organisation (ILO), there are more than 2.3 million deaths per year globally as a result of accidents at work 1 or work-related diseases. In developed countries, annual workplace fatal accident rates are typically between 0.5 and 3.5 per 100,000 workers. By contrast, the ILO estimates an annual global average rate of around 13 fatalities per 100,000, while rates in the emerging markets of sub-saharan Africa, South Asia and Latin America are estimated at between 17 and 19 per 100, The numbers above are stark and a reminder of how challenging it is to reduce workplace fatalities and serious accidents in emerging markets. In this context, investors have a great opportunity to address fatal accidents by assisting the creation of a clear, riskbased approach to health and safety management, backed at a senior level within a company. Investors in emerging markets may initially encounter poor understanding of environmental and social practice in the workplace (including standards of health and safety) and are aware that there is often limited enforcement by the state or sanctions for companies/contractors whose health and safety performance is poor. CDC s mission Our mission is to support the building of businesses throughout Africa and South Asia, to create jobs and make a lasting difference to people s lives in some of the world s poorest places. We believe job creation is essential both in Africa and South Asia, where two thirds of those of working age today are without formal jobs and where demographic growth will hugely exacerbate this challenge over the next decade. At a human level, employment has a transformative effect on the life of individuals and their families and dependents. So we recognise the profound implications that any incident involving serious injury or loss of life can have on the person affected as well as on their family and dependents. We are determined to work with our investment partners to reduce these incidents. 2.3m+ According to the International Labour Organisation (ILO), there are more than 2.3 million deaths per year globally as a result of accidents at work 1 or work related diseases. 1 An adverse event that results in injury/death/ill health or some other loss or damage. 2 Research conducted by Hamalainen, Saarela and Takala in Journal of Safety Research (40) 2009 pp , suggested that under 5% of accidents estimated to have happened annually are actually formally reported to the ILO.

7 05 1A. Context Introduction to the good practice note The cost Aside from the human tragedy and wider implications, there are also considerable economic and business costs to accidents. The ILO estimates the cost of workplace accidents to be around 4% of global Gross Domestic Product, or put another way, workplace accidents have a significant impact upon company performance. Many of these costs are not covered by insurance. Addressing accidents (as part of investors broader focus on workplace health and safety) is therefore a material consideration in the sectors and locations where CDC and its fund managers invest. Through this Good Practice Guide, CDC intends to provide practical guidance and to demonstrate what investors can do to help reduce workplace accidents. 4% GDP The ILO estimates the cost of workplace accidents to be around 4% of global Gross Domestic Product. Fig 1. 3 Typical annual workplace fatal accident rates per 100,000 workers sub-saharan Africa, South Asia and Latin America Developed countries 3 Global average of 13 fatalities per 100,000 employees whilst the ILO also believes there is significant underreporting in some markets.

8 06 Context B. CDC s experience and objective for this guidance Background CDC asks all investees and fund managers who manage its capital to report fatal workplace accidents, including accidents involving contractors. This exercise has a dual purpose. Of highest priority is to avoid the repetition of similar accidents through the effective implementation of appropriate corrective and preventive actions and to ensure that the fund manager/company management is adequately committed to improving workplace conditions. A secondary purpose is to ensure that CDC capital fosters better Occupational Health and Safety (OHS) performance. Between 2010 and 2013, 161 fatalities were reported to CDC from the portfolio companies in which CDC s capital is invested 4. The victims of these 161 fatalities were employees and contractors working at a company where CDC s capital is invested. In 2013, there were 62 workplace fatalities suffered by employees and contractors. Between 2010 and 2013, the distribution of fatal accidents by industry sector was as shown opposite in Fig 2. CDC s portfolio has suffered fatal accidents in industry sectors including utilities (e.g. construction of power stations and distribution networks), transport and logistics, manufacturing, forestry and fishery. There is some correlation with findings of the US Bureau of Labor which identifies forestry, transport and mining as particularly high risk industry sectors 5. CDC has also analysed the fatalities in its portfolio to assess the types of activity being undertaken when the fatal accident occurred 6. Objective of this document Based on the information and the clustering of fatalities around certain sectors and activities, CDC believes there is value in providing practical and concise guidance to investors and managers on how to help prevent accidents. CDC s aim is to help investors and managers understand how to minimise risks of fatal/serious incidents, and how to react when they encounter them, to help prevent future accidents. CDC s approach is framed against the broader backdrop of integrating Health and Safety (HS) considerations at portfolio companies into the investment process. Key accident-related health and safety principles are outlined in Section 1D, although elsewhere the guide is designed to be non-technical/specialised. Throughout, there will be particular emphasis on preventing the types of serious accidents identified through information from CDC s portfolio. The guide will also show how investors and managers can use their influence to impact positively on the causal factors relating to particular types of accidents. There are other workplace health and safety risks (e.g. exposure to hazardous chemicals, work-related stress, muscular-skeletal disorder risks, and fire and explosion risks) not expressly included in this guide. These are also relevant and if not addressed, may also lead to serious or fatal accidents. The explicit focus here is on preventing the occurrence of fatal and serious accidents which are deemed more frequent in CDC s portfolio based on data reported. Section 3B presents a framework that can be used when encountering HS risks/hazards not explicitly referenced within this guide. 4 CDC-backed companies employed around 1,113,000 employees in All accidents analysed here occurred at investee businesses of CDC s private equity fund portfolio. 5 United States Department of Labor, Bureau of Labor Statistics, Fatal Occupational Injuries, total hours worked, and rates of fatal occupational injuries by selected worker characteristics, occupations and industries, civilian workers, See 6 Since CDC aims to invest in sectors where its job creation focus can have the greatest impact, its investments are skewed towards certain sectors; therefore the breakdown of fatalities by sector would differs from more general trends cited in studies.

9 Utilities Transport Other 8 Manufacturing heavy Communication Construction Mineral extraction Forestry and fishery Manufacturing light Road traffic accident Other 10 Fall from height Contact with moving machinery/ flying/falling object Acts of violence Struck by moving/ workplace vehicle Contact with electricity/ electrical discharge 1B. Context CDC s experience and objective for this guidance Fig 2. Fatal accidents by sector in CDC s portfolio (%) Fig 3. Activities resulting in employee/contractor fatal accidents in CDC s portfolio (%) Numbers based on fatal incidents reported to CDC between 2010 and 2013 in relation to fatalities involving employees/contractors. Construction may be included in other sectors. 8 Other includes business services, financial services and public services. 9 Numbers based on fatal incidents reported to CDC between 2010 and Other types of accident includes entering excavations, confined spaces, drowning, exposure to hazardous substances, etc.

10 08 Context C. Cost and impact of accidents Business costs Serious and fatal accidents can be visualised as being the top of a pyramid with a significantly larger number of less-serious accidents (and no-injury accidents) beneath. In the 1950s, Herbert William Heinrich suggested the ratio shown in Fig Whilst many different versions of these ratios have been developed subsequently, the key point is a simple one that for every major injury accident, there have typically been around 300 less serious accidents. Each of these less-serious accidents needs to be viewed as an opportunity to learn and apply a corrective/preventive action approach to manage risk. Applied across an organisation, such an approach can significantly reduce the likelihood of a more serious accident. There is, as one might expect, no predicting when each accident type will occur and of course the nature and type of the minor accident may not directly link to that of a major accident. Thus, tackling the no-injury accidents in itself will not eliminate major accidents, but will develop a systematic approach to safety that reduces their likelihood. The real picture is more complex than this, but from an investor s perspective, it is clear that the 300 no-injury accidents are, when considered together, likely to have a significant detrimental impact (both financial and non-financial) upon an organisation. This illustrates why investors need to understand a company s approach to all accidents, specifically reporting, investigation and corrective actions, not just those making headline news. Human costs Research shows that in developing economies, a single worker will typically support four or five dependents 12, including their family. If a worker dies or is injured and unable to work, the impact on that person s dependents may include: In the absence of a welfare safety net, loss of wages means no money for food, shelter and clothing; Children s school fees and family medical bills may go unpaid, with implications at health and education levels; and Other family members, including children, may be forced to seek paid employment, preventing them from pursuing their studies. Business implications In addition to the human impact, accidents bring a range of other commercial impacts including: Downtime: serious accidents can lead to and legally require temporary site shut downs until an external authority gives permission to re-open; Loss of production: and resulting losses due to issues such as power-down and power-up time; Loss of equipment: vehicles, facilities, etc; Morale: lower productivity and higher staff turnover; Loss of business: buyers changing suppliers, contractors being dropped; and Adverse publicity: and damaged reputation. Each of these represents real costs to a company, most of which are not likely to be covered by insurance. The ILO estimates that around 4% of GDP is lost due to work-related accidents and ill health. Ensuring a company is clearly focused on managing safety in the workplace is therefore not a merely ethical issue, it is a sound commercial one. Fig 4. Cost of accidents Insured Not insured $1 $10 The UK Health and Safety Executive (HSE) estimated in 2012 that uninsured losses associated with an accident are at least ten times the value of any insurance premiums paid. An analogy of an iceberg is often used where hidden costs are those below the water and which are not typically covered by insurance. Insured: injury, loss, damage, ill health. Not insured: loss of production, power down, power up, delays to production, loss of business, reputational damage, investigation time, clean-up/ clear up, claim excess, overtime, impact on morale, impact on recruitment and retention of staff. It is worth noting that government backed employment injury insurance coverage in sub-saharan Africa is estimated by ILO to cover as little as 10% of the workforce. 11 Heinrich, Industrial Accident Prevention, 3rd edition, Bongaarts J. 2011, Can family planning programs reduce high desired family size in sub-saharan Africa? International Perspectives on Sexual and Reproductive Health Dec;37(4):

11 09 Fig 5. Herbert William Heinrich Ratio The key to preventing major accidents and fatalities in the workplace is to ensure a systematic approach to investigating all accidents and incorporating the lessons learned into a robust, risk-based approach to safe working across the organisation. 1C. Context Costs and impact of accidents 1 major injury 10 minor injuries 300 no injury incidents For every major injury accident within an organisation, there are typically around 300 less serious incidents.

12 10 Context D. Key principles of applying health and safety theory to accidents Introduction Workplace accidents are not an inevitable consequence of economic activity, and as CDC data demonstrates they are not confined to highly complex industry sectors which are acknowledged as being of high risk (e.g. construction) and can occur as a result of everyday activities being undertaken in the workplace. Investors should be aware that accidents occur for a number of reasons and that it is necessary to look beyond direct level factors (which represent the immediate cause of the accident) to get to environmental and policy failings that can be addressed in order to prevent repetition. Root cause of accidents This diagram shows how investors can be more strategic and go beyond identifying the agent of injury in order to consider root cause and thereby use their influence to change company behaviour and culture. See also Section 3A: Investor Response to Accidents. This guide is primarily focused on accidents, but at macro level, fatal and serious accidents have a range of causal factors. Hazards and risks Most accidents can therefore be prevented through the application of simple measures to effectively identify hazards, and properly control risks. A hazard is a source of potential, damage, harm or adverse effect including ill health and injury (e.g. electricity). A risk is the probability and severity of the damage, harm or adverse effect occurring. If investors understand both terms and think along the lines of the potential causes above, they can prioritise accident prevention measures that really matter. Investors should have a general understanding of the main hazards and risks present within an organisation. This will be the result of the due diligence work undertaken in advance of the investment decision, and the subsequent application of relevant international standards such as the International Finance Corporation (IFC) Performance Standards on Environmental and Social Sustainability, backed by the EHS Guidelines (particularly, Section 2: OHS or equivalent standards and Section 3: Community Health and Safety).

13 11 Fig 6. Why do accidents happen? 1D. Context Key principles of applying health and safety theory to accidents Accidents often have numerous causes, which have developed over a period of time and in such a combination as to have made an accident virtually inevitable. Causation levels Root causes The failure from which all other failings grow. Can be distant in relation to time and space from the accident, and is often linked to how an organisation is managed. Investors role Investors have most significant influence here (e.g. Board seat/due diligence and specialist access/ site visits) in reducing potential root causes of accidents through the promotion and support of initiatives to improve the management of safety within an organisation. Underlying causes Unsafe acts (e.g. balancing on a ladder) and unsafe conditions (e.g. working outside in windy weather). Direct level causes (agent of injury) E.g. sharp tool/contact with ground. Investors will rarely be on site when an accident occurs although they may observe, or become aware of unsafe acts and conditions which they could challenge. Hence, it is vital that they use their influence to establish a positive HS culture at portfolio companies. Investors should follow up on the accident (root cause analysis or RCA) and notify their own investors such as CDC via the Template Accident Report. Accident Continued overleaf >

14 12 Fig 7. Accidents: relevant factors to consider Socio-economic and regulatory context factors Social (e.g. low cost of labour), cultural (e.g. poor enforcement/regulation), commercial (e.g. buyer-seller contracts), political, regulatory. Corporate policy level factors Contracting strategy, company culture, ownership and control, HS management, labour relations, profitability. Organisational level factors Training, procedures, planning, supervision, communication, HS culture, attitude to risk, equipment purchasing, inspection, maintenance, process design, contracting. Direct level factors Competence, motivation/morale, team working, situational awareness, risk perception, fatigue, health, information, advice, operational equipment, safety equipment, environmental conditions. Accidents are caused by each of the above levels Accident

15 13 Fig 8. Prevention principles 1D. Context Key principles of applying health and safety theory to accidents Prioritisation Prioritisation is important when considering the management of workplace risk through the implementation of measures to eliminate and, where not possible, reduce the level of risk to an acceptable level. This level should be consistent with good international industry practice 13 as reflected in various internationally recognised sources including the World Bank Group Environmental, Health and Safety Guidelines. Prioritisation should be done intelligently avoid prioritising the easiest actions exclusively at the expense of considering materiality. Key principles 1. Eliminating or reducing hazards for example by substitution, replacing the dangerous with the less dangerous. 2. Isolating or controlling the hazard at source, for example through engineering controls. 3. Minimising the risk through design and use of safe systems of work. 4. Providing appropriate protective measures (e.g. PPE), prioritising the reduction of risk for the collective over that for the individual. Prioritisation Most likely to be effective at reducing risk of injury occurring, although may not always be technically feasible. More likely to be effective at reducing risk of injury occurring, provided isolation/control devices are robust and not easily overridden. Likely to be effective at reducing risk of injury occurring but requires information, training, support and reinforcement. Should always be implemented when are not sufficient to reduce the risk but should not be prioritised over Reinforcing safe behaviours. Most evident in companies with mature risk management regimes, seeking to refine further their HS performance (see Section 1E). Should not be prioritised over Crosscutting Providing safety awareness as well as risk/activity-focused refresher training is necessary at all levels of the HS management hierarchy. Appropriate training is a requirement across all levels of an organisation, and is a fundamental component of developing a credible safety culture. 13 Defined as the exercise of professional skill, diligence, and foresight that would reasonably be expected from skilled and experienced professionals engaged in the same type of undertaking under the same or similar circumstances, globally or regionally.

16 14 Context E. What investors can do Fig 9. Integrating health and safety Health and safety/accident prevention within the investment process 1. Site visit Purpose Actions Gather information through a wellconducted site inspection together with interviews with key personnel. This can provide an indication as to the general approach to HS; Observe working practices and, where possible, speak with workers directly to gather further information. Remember to take effective measures to secure your own health and safety. Site visit to portfolio company prioritise what you visit based on where you expect hazards to be located; Access client capacity, commitment and track record by asking questions with informed follow up. Tools > Section 3B Due diligence guidance of this document and Section 2 of this document; > CDC Toolkit on ESG for fund managers.

17 15 1E. Context What investors can do 2. Due diligence: professional support 3. Legal terms 4. Monitoring Specialist HS consultants should be involved in assisting with the making of an informed investment decision where significant hazards and risks are suspected; Advise on extent of operational risk. Communicate clearly to the company what is expected by way of improvements; Use cost and impacts arguments to persuade management as necessary. Follow up to ensure implementation of what is agreed; Be efficient in anticipating/addressing future issues (continuous monitoring); Consider additional review when accidents occur. Expert consultants to spend time understanding the approach/culture of HS within the company; Expert consultant can provide some indication of the magnitude of the risk, and give an outline of potential corrective actions and the implications of these to inform investment decision. > Section 1D and 3A/B for hazard/ risk identification; > Section 2 to inform consultant Terms of Reference (TOR). Require portfolio company to implement an agreed clear and time-bound action plan as part of their investment agreement; Consider accreditation to a recognised HS management system and/or the appointment of a competent HS professional where none presently exists. > Section 1E of this document; > Section 1C of this document; > OSHAS and CDC Toolkit on ESG for fund managers and HSG Use channels of influence (Board meetings, investor visits); Repeat site visits to monitor compliance and note observations via a progress report; Consider if external specialists/ ongoing audits are required especially when accidents repeat themselves or there is evidence of system/process failures. > Section 2 of this document for tips on site visits.

18 16 Context E. What investors can do investor interventions Investor guidance The due diligence guide in Section 3B provides investors with a means of assessing a portfolio company s approach to health and safety, specifically in relation to accident prevention. It is structured in terms of assessing client capacity, commitment and track record. Linking to the accident cause hierarchy in Section 1D above, investors can think in terms of: Capacity. Does the client have the capacity to identify hazards and significant risks and prioritise using an HS hierarchy above? Commitment. Is senior management aligned and can the company demonstrate processes to avoid accidents on the ground? Track record. Does the data back up the statements/documentation provided by senior management? Sector focus Investors can also consider what workplace risk areas may be particularly prevalent in the industry sector in which they are considering investing. The table in Fig 8. provides some guidance. It is not a definitive view, but rather serves to illustrate, based on analysis of CDC data, areas of potentially greatest risk across each sector. Investors may wish to refer to this table to in order to prioritise their HS approach to specific companies. Focus on risk areas Where particular risk areas are identified, investors should consider supplementing general questions in Section 3B with the specific guidance by type of activity in Section 2 below. Accident prevention post-investment During the monitoring phase, investors will most likely not be on the ground when accidents occur and may be geographically remote from the scene. Proactive monitoring is key and investors should ensure that they know the hazard burden, understand how the company is organised to effectively manage the resultant risks and have obtained sufficient reassurance that this is happening. There are still a range of means through which investors can be both proactive and reactive depending on circumstance. These are outlined on the page opposite. Proactive interventions Investors can influence and monitor a company s performance via: Use of Board presence/management contacts to explain the relevance of adequate occupational health and safety management practices and to ask questions on occupational health and safety strategies, objectives, management measures and performance. Site visits to operational sites allow information gathering at both manager level and if possible at worker level (with a focus on industry sectors/activities that are known to be high risk); Requesting emergency planning and response provisions (first responder, first aid and evacuation, medical support, critical plant and equipment fail-safe systems, reporting and notification systems, recovery plans); Overseeing accident investigation, followup and corrective action management procedures (root cause approach see Section 8, access to expertise, linkage to management of operational risk); and Re-enforcing safe behaviour Investors and senior management should set the tone when visiting operational facilities (wear PPE, insist on a safety briefing, dedicated discussion time on HS at Board meetings). Reactive interventions to accidents Understand what has happened, why, what is planned to avoid recurrence and request evidence and/or provide assistance to ensure that planned actions have been implemented and are working. Investor response should include: Review of key facts, communicated within a reasonable time frame (what has happened, injuries/fatalities/loss/ damage, immediate actions undertaken, current status and schedule of further communication and root causes); Management response to investigation findings and finalised corrective/preventive action plan (allocated, time-lined and budgeted where necessary), counselling for staff/reassurance that company is acting on the accident and eliminating, or where not possible, addressing/reducing likelihood of future accidents; Confirmation that plan has been successfully implemented and that the objectives of the plan have been met; and Require additional reassurance, in the form of a third party review of the effectiveness of risk control measures in the event of recurring accidents, especially when of a similar type.

19 17 Fig 10. Identifying risk areas by industry sector 1E. Context What investors can do Investor interventions Risk area leading to serious or fatal accidents 14 Sectors 15 Utilities Transport Mineral Manufacturing light Manufacturing heavy Forestry Construction Communication Contractors Working at height Workplace vehicles Moving machinery Flying/falling objects Occupational road risk Electricity Priority area (analysis shows a strong prevalence for this risk area within this sector) investors should seek reassurance that risk is managed as a priority Case-by-case (analysis does not show a strong prevalence for this risk area) investors should seek reassurance that risk is managed on a case-by-case basis 14 Only risk areas identified as the most relevant based on data reported to CDC. Other risks may be present and may cause fatal/serious incidents if not properly managed. 15 The classification of sectors used here relates to those sectors where accidents frequently occur according to CDC data. These are not the same as the sectors used for CDC s development impact grid.

20 18 Context E. What investors can do certification and ongoing investment Establishing a safety culture The establishment of a risk and safety management system, whether certified or not, is a key step towards reducing workplace accidents. However, for such a system to be effective, the organisation needs to ensure safety considerations are fully integrated into the business at every level. For this to happen, everyone working in or for the organisation must understand the importance of safety, the part they play in it, and the importance attached to it by the organisation. In the best organisations, this becomes a set of shared values, frequently referred to as a safety culture, and evidenced through understanding, commitment and safe behaviour from the boardroom to the factory floor, construction site, mine or any other workplace. In the most safety-conscious organisations, there is a heavy emphasis on safety as the number one priority, backed by continuous monitoring, site inspections and consequent improvements reflecting lessons learned and advances in risk management within the sector. Typically, an open approach to risk management, communication and positive reinforcement of safe behaviours serve to support such an approach. Health and safety certification CDC strongly encourages investors and its managers to implement a formal approach to managing HS/accident-related issues within their portfolio companies. One of the most widely adopted initiatives is OHSAS 18001: ohsas occupational-health-andsafety This is an internationally recognised HS management system, based on a Plan, Do, Act, Check, Improve approach. OHSAS is expected to become ISO in 2016, in order to fully align with ISO 9001 and ISO Other management systems worth considering in relation to health and safety include the recently revised and streamlined UK HSEdeveloped management tool HSG 65. As previously indicated, while the establishment of a management system (even a certified management system) is a vital first step, it is not sufficient in isolation as it must be accompanied by the growth and development of a safety culture as outlined above. The key to reducing accidents is to ensure that this culture creates an environment where individuals know that safety comes first, and consequently understand that safe behaviour in support of this is reinforced. What does an effective risk assessment look like? Frequently, the term risk assessment is used as a catch-all term to refer to a document claiming to demonstrate sound HS management for a given activity. However, risk assessment is a process, and any documented output from it should include the following: Clear description of activity and identification of hazards; Who will do it and their competencies, where, when, for how long and what resources and equipment will be required; Balanced evaluation of risks with directly linked control measures; Details/evidence of involvement of workforce and appropriate professionals/ third-parties; and Evidence of implementation (including training/translation as needed, insertion into working procedure, provision of equipment), review of effectiveness, and revisions to improve effectiveness. Excessively wordy documents are unlikely to be followed and may not be fully understood. Those with clear, simple messages work best at controlling risk. Crucially, both workers and managers should be able to explain the provisions of any risk assessment document, and outline their individual responsibilities to ensure that it is followed.

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